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2022 (3) TMI 434

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....RDER PER C.M. GARG, JM This is an appeal filed by the revenue against the order of the CIT(A),1, Bhubaneswar dated 13.12.2019 for the assessment year 2012-13. 2. The appeal is time barred by 346 days. The revenue has filed condonaton petition to condone the delay in filing the appeal before the Tribunal, stating that the limitation to file appeal before the Tribunal has expired due to the fact ....

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....venue is condoned and the appeal is admitted for adjudication. 4. The revenue is aggrieved by the order of the ld CIT(A) in giving relief of Rs. 11,44,366/- by restricting the disallowance in respect of interest payment on mobilisation advance to Rs. 34,40,315/-. 5. At the outset, ld A.R. of the assessee submitted that the revenue has come in appeal against the relief of Rs. 11,44,336/- given by....

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....cular, only enhances the monetary limits and gives further relaxation. The old circular, beyond any dispute or controversy, categorically applied to the pending appeals as on the date of issuance of circular. 8. The circular dated 8th August 2019 is not a standalone circular. It is to be read in conjunction with the CBDT circular No. 3/2018 (subsequent amendment thereto), and all it does is to re....

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....n which it can be demonstrated that the appeals are covered by the exceptions, and (ii) which are inadvertently included in this bunch of appeals, wherein the tax effect, in terms of the CBDT circular (supra), exceeds Rs. 50,00,000. 11. We accept the request of ld CIT D.R. We make it clear that the appellant shall be at liberty to point out the case which is wrongly included in the appeal so su....